Background

• Two law-enforcement agencies received a tip that room 216 at a Super 8 in Lewiston, Maine held drugs; room 218 was adjacent and later involved.
• Agents knocked on room 216; no one answered, but Bonnett and Aiken appeared at room 218’s door; Aiken was barefoot in shorts and partially hidden behind Bonnett.
• Officers entered room 218, observed marijuana and a dusted cocaine base scale, and found a bag of cocaine/base in a nightstand drawer, prompting a search warrant.
• The district court initially suppressed the evidence, finding Aiken and Bonnett had a reasonable expectation of privacy in the motel room; the government appealed.
• The First Circuit reversed and remanded, holding Aiken lacked a permissible Fourth Amendment expectation of privacy in the motel room; ultimately the case turned on whether Aiken was an overnight guest with a protectable privacy interest.
• Key issue: whether Aiken had a reasonable expectation of privacy in the motel room; the court concluded he did not prove such an objectively reasonable expectation.

Issues

Key Cases Cited

• Minnesota v. Olson, 495 U.S. 91 (1990) (overnight guest has privacy expectation in host's home)
• Rakas v. Illinois, 439 U.S. 128 (1978) (possession of permission to be present does not by itself establish privacy)
• United States v. Carter, 525 U.S. 83 (1998) (brief, commercial-like or transient stay may negate privacy expectations)
• Owens, 167 F.3d 739 (1999) (draw all reasonable inferences in favor of suppression ruling)
• McGregor, 650 F.3d 813 (2011) (duty to draw reasonable inferences in weighing reasonable-privacy determinations)
• United States v. Bain, 874 F.3d 1 (2017) (over overnight-guest status can establish privacy in shared residence)